In 1970, Congress passed the Currency and Foreign Transactions Reporting Act commonly known as the “Bank Secrecy Act” (BSA), establishing recordkeeping and reporting requirements by private individuals, banks and other financial institutions. The BSA is intended to safeguard the U.S. financial system and the financial institutions that make up that system from the abuses of financial crime, including money laundering, terrorist financing and other illicit financial transactions.
All credit unions must comply with the BSA regulations.
To assist credit unions with their efforts in establishing and maintaining procedures designed to assure and monitor compliance with the BSA, additional information and details are provided in the links to the right.
Please note the term “bank” is used interchangeably with “credit union” for ease in drafting joint statements from the FFIEC Agencies. Treasury and FinCEN regulations use the term “bank” to define a variety of financial institutions, including credit unions.
BSA Exam Resources
12 USC 1786(q)(2) requires that the National Credit Union Administration (NCUA) include a review of the BSA compliance program at each examination of a federally insured credit union. NCUA plays a critical role in implementing BSA regulations by developing examination guidance, ensuring compliance with the BSA and enforcing the BSA in federally insured credit unions.
Federal Financial Institutions Examination Council (FFIEC) BSA/AML Examination Manual
Bank Secrecy Act - Increased Use of Exemption Provisions Could Reduce Currency Transaction Reporting (CTR) While Maintaining Usefulness to Law Enforcement Efforts - The Government Accountability Office (GAO) report to congressional committees on the usefulness of CTRs to law enforcement, the costs of meeting CTR requirements to depository institutions, and ways to encourage use of exemptions to avoid unnecessary CTRs.
Financial Crimes Enforcement Network (FinCEN) - FinCEN, a bureau of the U.S. Treasury, is the delegated administrator of the BSA. In this capacity, FinCEN issues regulations and interpretive guidance, provides outreach to regulated industries, supports the examination functions performed by federal banking agencies and pursues civil enforcement actions when warranted.
There are several ways to contact the Financial Crimes Enforcement Network. The following contact information is provided to help direct your inquiries to the appropriate offices and/or personnel.
U.S. Department of Treasury and Federal Banking Agencies Joint Fact Sheet on Foreign Correspondent Banking
(703) 905-3591 (Monday thru Friday, 8:30 a.m. - 8:00 p.m., E.S.T.)
- For the general public with questions about the Financial Crimes Enforcement Network, its policies and programs.
Regulatory Toll-Free Helpline
1-800-949-2732 (Monday thru Friday, 8:00 a.m. - 5:00 p.m., E.S.T.)
- For financial institutions with questions relating to Bank Secrecy Act and USA PATRIOT Act requirements and forms.
Financial Institutions Toll-Free Hotline
1-866-556-3974 (7 days a week, 24 hours a day)
- For financial institutions wanting to report suspicious transactions that may relate to terrorist activity. The purpose of the hotline is to facilitate the immediate transmittal of this information to law enforcement.
While not an inclusive list, links to several reports on FinCEN’s website are provided below. You are encouraged to visit FinCEN’s home page for an inclusive list of all BSA related resources.
SAR Activity Review Trends, Tips and Issues: These reports are issued twice a year and provide analyses of trends, tips and issues about the preparation, use and utility of Suspicious Activity Reports.
SAR Activity Review - By the Numbers: A compilation of numerical data gathered from Suspicious Activity Reports filed by depository institutions certain money services, casinos and card clubs, and certain segments of the securities and futures industries.
Advisories, Rulings, Bulletins, Fact Sheets: Provide additional guidance and information regarding the BSA.
- 314(a) Information Requests: FinCEN regularly requests credit unions search records for persons that may be involved in terrorism or money laundering. Requests are sent to points of contact (POCs) at credit unions. If you need to change your POC, please file an amended Call Report with the updated information.
Money Services Business (MSB) Website:
U.S. Money Laundering Threat Assessment (MLTA): The MLTA offers a detailed analysis of money laundering methods in the United States, ranging from well-established techniques for integrating dirty money into the financial system to modern innovations that exploit global payment networks as well as the Internet.
2007 National Money Laundering Strategy: The 2007 Strategy addresses the priority threats and vulnerabilities identified by the Money Laundering Threat Assessment released in 2006.
Financial Action Task Force (FATF) Reports: The Financial Action Task Force (FATF) is an inter-governmental body whose purpose is the development and promotion of national and international policies to combat money laundering and terrorist financing.
High Intensity Financial Crimes Areas (HIFCAS): This is a means of concentrating law enforcement efforts at the federal, state and local levels in high intensity money laundering zones.
High Intensity Drug Trafficking Areas (HIDTAs): HIDTAs are areas within the United States that exhibit serious drug trafficking problems and harmfully impact other areas of the country.
International Narcotics Control Strategy Report (INCSR), published annually by the U.S. State Department identifies major money laundering countries and jurisdictions.
Cornerstone: A U.S. Immigration and Customs Enforcement’s (ICE) comprehensive investigative initiative for fighting financial crime, trade fraud and intellectual property crime. The Cornerstone Report is a quarterly bulletin highlighting key issues related to ICE financial and trade investigations.
For federally insured credit unions, the BSA is addressed in Part 748 of the NCUA Rules and Regulations and Title 31 of the Code of Federal Regulations. The links to these regulations are provided below.
The Financial Crimes Enforcement Network encourages the use of electronic filing of Bank Secrecy Act forms. Go to
Suspicious Activity Reports (SAR)